Civil Tax

Attorneys representing cannabis businesses are often faced with questions about what happens when the cannabis business has not paid its taxes and the IRS is proceeding with collection actions.  No…
Continue Reading IRS Guidance to Field: Deep Clean Equipment Used in Cannabis Businesses Before Selling

United States v. Gerard, a recent case from the Northern District of Indiana, demonstrates how a tax lien, once attached, can stay with property even after the property is…
Continue Reading District Court Holds Tax Liens Stay with Property after Conveyance

The White House released a statement on February 8, 2018 that President Trump nominated Charles Rettig as the new Commissioner of Internal Revenue Code for the remainder of a five…
Continue Reading Charles Rettig – From Private Practice to President Trump’s Nominee for IRS Commissioner

In United States v. Stein, the Eleventh Circuit recently decided a novel – but critical – issue for taxpayers.  It held that an affidavit that satisfies Rule 56 of…
Continue Reading Eleventh Circuit Cuts into Presumption of Correctness Standard for IRS Assessments

In Mission Funding Alpha, the Pennsylvania Supreme Court recently held that the statute of limitations for a corporation to file a refund claim in Pennsylvania begins to run when…
Continue Reading Pennsylvania Supreme Court: Corporate Tax Refund Claim Must Be Filed Within Three Years Of Original Tax Return Due Date

We have all heard the old proverb “if it’s too good to be true, then it probably is.” In the tax world, this proverb might as well be referred to…
Continue Reading Take Heed: Tax Planning Too Good To Be True? It Might Be…And Taxpayers Can Be Penalized